1

DOCKET NO: A-98-49 

Item: II-B3-111 

2009 - Monitoring Inspection Report

INSPECTION No. EPA-WIPP-7.09-14b 

OF THE 

WASTE ISOLATION PILOT PLANT 

July 14 to July 16, 2009 

U. S. ENVIRONMENTAL PROTECTION AGENCY 

Office of Radiation and Indoor Air 

Center for Waste Management and Federal Regulation 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

September 2009
2 

 Table of Contents 

1.0 Executive Summary...................................................................................................................3 

2.0 Scope..........................................................................................................................................3 

3.0 Inspection Team, Observers, and Participants...........................................................................4 

4.0 Performance of the Inspection ...................................................................................................5 

 4.1 Monitoring of Geomechanical Parameters .............................................................................5 

 4.2 Monitoring of Hydrological Parameters .................................................................................7 

 4.3 Monitoring of Waste Activity Parameters ..............................................................................7 

 4.4 Monitoring of Drilling Related Parameters ............................................................................8 

 4.5 Monitoring of Subsidence Parameters....................................................................................9

5.0 Summary of Findings.................................................................................................................9 

Tables

Table 1 Monitored Parameters 

Table 2 Geomechanical Parameter and Values Measured to Confirm Them 

Attachments

Attachment A Inspection Plan and Checklist 

Attachment B Documents Reviewed 
Page 3 of 17

1.0 Executive Summary

 The U.S. Environmental Protection Agency (EPA) conducted an inspection of the 

Department of Energy’s (DOE) Waste Isolation Pilot Plant (WIPP) from July 14 to July 16, 

2009, as part of our continuing WIPP oversight program. The purpose of this inspection was to 

verify that DOE continues to adequately monitor ten parameters listed in the Compliance 

Certification Application (CCA), Volume 1, Section 7.0, in particular Table 7-7 (See Table 1, 

COB-M2009-1). Attachment A contains the inspection plan and the checklist used by the EPA 

inspector, and Attachment B lists documents reviewed by the EPA. 

 The inspection examined the implementation of monitoring for geomechanical, 

hydrological, waste activity, drilling related, and subsidence parameters. The EPA inspectors 

toured locations where measurements are taken, reviewed parameter databases, and reviewed 

documents and procedures directing these monitoring activities. 

 EPA found that DOE has effectively implemented the monitoring programs at WIPP for 

all areas reviewed. EPA did not have any findings or concerns. The inspectors also confirmed 

that the results of DOE monitoring programs are reported annually. 

2.0 Scope

 The EPA WIPP Compliance Criteria (40 CFR Part 194.42(a)) require DOE to “conduct 

an analysis of the effects of disposal system parameters on the containment of waste in the 

disposal system.” The results of these analyses were included in the 1996 Compliance 

Certification Application (CCA), confirmed in the 2004 Compliance Recertification Application 

(CRA), and were used to develop pre-closure and post-closure monitoring requirements. 

 Volume 1, Section 7.0, of the CCA documented DOE’s analysis of monitoring 

parameters. Table 7-7 of the CCA lists the ten parameters that DOE determined may affect the 

disposal system. These parameters are grouped into major categories and listed in Table 1. EPA 

accepted these ten monitoring parameters in the 1998 Certification Decision and confirmed them 

in the 2006 Recertification Decision. 
Page 4 of 17

Table 1 - Monitored Parameters

Geomechanical Parameters- Waste Activity Parameter- 

 -Creep closure, -Waste Activity 

 -Extent of deformation, 

 -Initiation of brittle deformation, and Subsidence Parameter- 

 -Displacement of deformation features. -Subsidence measurements 

Hydrological Parameters- Drilling Related Parameters- 

 -Culebra groundwater composition and -Drilling rate and 

 -Change in Culebra groundwater flow -The probability of encountering a 

 direction. Castile brine reservoir. 

 This inspection was performed under authority of 40 CFR 194.21, which authorizes EPA 

to verify the continued effectiveness of the parameter monitoring program at WIPP. Inspection 

activities included an examination of monitoring and sampling equipment both on and off site, 

and in the underground. EPA also reviewed numerous sampling procedures and measurement 

techniques and verified implementation of an effective quality assurance program (see the 

document list in Attachment B of this report). 

3.0 Inspection Team, Observers, and Participants

 The inspection team consisted of four EPA staff. Thomas Kesterson of the State of New 

Mexico Environmental Department observed the inspection. 

Inspection Team Member Position Affiliation

Chuck Byrum Inspection Leader EPA 

Nick Stone Inspector EPA 

Tom Peake Inspector EPA 

Jonathan Walsh Inspector EPA 
Page 5 of 17

 Numerous DOE staff and contractors participated in the inspection; below is a partial list. 

DOE/Contractor Participants

Dan Ferguson Dave Speed 

Joel Siegel Dave Kump 

Rey Carrasco Stan Patchet 

John VandeKraats Art Chavez 

David Hughes Mansour Akbarzadeh 

Larry Madl Ben Zimmerly 

4.0 Performance of the Inspection 

The inspection began on Tuesday, July 14, 2009, with an opening meeting (COB-A2009-

S1a, -S1b) where changes in the parameter monitoring programs since the previous inspection 

were discussed by site staff (COB-M2009-I1 to –I10). On July 15, 2009, the inspection 

continued with interviews and demonstrations of various aspects of each parameter monitoring 

area. On July 16, 2009, EPA inspectors examined the database(s) used to store Delaware Basin 

parameters and the WIPP Waste Information System (WWIS) waste computer database system. 

The underground, where geomechanical measurements are taken, was also inspected on July 15, 

2009. The inspection closeout meeting was held on July 16, 2009, in Carlsbad New Mexico 

(Sign-in sheet COB-A2009-S1a). 

 The Agency reviewed three fundamental areas to verify continued implementation of the 

DOE parameter monitoring program during the pre-closure phase: 1) written plans and 

procedures, 2) quality assurance procedures and records, and 3) results of the monitoring 

program in the form of raw data, intermediate reports, and final annual reports, if appropriate. 

The inspection checklist in Attachment A provides details of these inspection activities. 

EPA also reviewed various activities to verify effective procedure implementation. The 

inspector observed a demonstration of the WWIS and reviewed the Delaware Basin Drilling 

Surveillance Program, Groundwater Monitoring Program, and the Geomechanical Monitoring 

Program. 

4.1 Monitoring of Geomechanical Parameters

 DOE committed to measure four geomechanical parameters in the CCA: creep closure, 

extent of deformation, initiation of brittle deformation, and displacement of deformation features 
Page 6 of 17

(Table 2). WIPP has four programs that supply information for these four parameters: the 

geomechanical monitoring program, the geosciences program, the ground control program, and 

the rock mechanics program. These programs are documented in the WIPP Geotechnical 

Engineering Program Plan, WP 07-01 (COB-M2009-E). The results of the geotechnical program 

are reported in the Geotechnical Analysis Report for July 2007 - June 2008, DOE/WIPP-09-

3177, Volumes 1 and 2 (COB-M2009-A1 and -A2). 

Table 2 - Geomechanical Parameter and Values Measured to Confirm Them 

Monitor Parameters Confirmed by Measuring Related Procedure(s)

creep closure and stresses convergence measurements WP 07-EU1301 

 borehole extensometers WP 07-EU1303 

 WP 07-EU1304 

 WP 07-EU1308 

extent of deformation borehole extensometers WP 07-EU1301 

 borehole observations WP 07-EU1303 

 WP 07-EU1305 

 WP 07-EU1308 

initiation of brittle fracture mapping WP 07-EU1301 

deformation borehole observation WP 07-EU1303 

 WP 07-EU1001 

displacement of deformation geologic mapping WP 07-EU1301 

features comparison WP 07-EU1303 

 WP 07-EU1001 

-From DOE/WIPP 09-3177 (COB-M2008-A1), Volume 1, Section 1.4 

 Geomechanical staff manually measured convergence values in the underground (Figure 

1, Horizontal Convergence Measurement) and the inspector examined the results documented in 

field data forms. After taking the measurements the inspector observed staff inputting these data 

into the computer database (COB-M2009-S42 to S47). The inspector found that procedures are 
Page 7 of 17

adequate for proper measurements; procedures are implemented adequately; documents and field 

data forms are controlled; and data is adequately checked, using check prints when necessary, to 

assure adequate quality. 

 

4.2 Monitoring of Hydrological Parameters

 DOE committed to measure two hydrological parameters in the CCA: Culebra 

groundwater composition and changes in the Culebra groundwater flow direction. Related 

parameters are measured and documented in the WIPP environmental monitoring program. 

These programs are documented in the WIPP Groundwater Monitoring Program Plan, WP 02-1 

(COB-M2009-C). Results of this program are published in the WIPP Site Environmental Report 

for 2007, DOE/WIPP 08-2225 (COB-A2009-C). This document describes the groundwater 

monitoring program and reports results for the previous year. 

 

 During the 2009 inspection, the EPA inspector requested information about changes in 

the program since last year. The opening meeting presentation noted that one new Culebra well 

was drilled, the H-4BR well to replace H4B (COB-M2009-I3). The current well monitoring 

network consists of 47 Culebra, 11 Magenta, three dual Culebra/Magenta completions, one 

Dewey Lake, two Bell Canyon, and 20 shallow Santa Rosa/Dewey Lake wells. Besides 

examining the Site Environmental Report for 2007, the inspector examined flow direction maps, 

well location maps, water level measurements, and water chemistry data (COB-M2009-S12 and -

S15). DOE and Sandia National Laboratory (SNL) implemented a new procedure to produce the 

potentiometric map used to estimate flow direction for the monitor requirements. The procedure 

is called “Preparation of Culebra Potentiometric Surface Contour Maps” (SP 9-9, COB-M2009-

S12). SNL present a presentation that described the use of this new procedure (COB-M2009-

S15). The inspector examined this new approach and found it to be adequate for this monitoring 

requirement. The inspector found the hydrological monitoring program to be improving and 

adequate. 

4.3 Monitoring of Waste Activity Parameters

 DOE committed to monitor the activity of waste emplaced in the CCA. This parameter is 

part of the extensive database collected for each container shipped to WIPP and is stored in the 

WIPP Waste Information System (WWIS). The WWIS is a software system that screens waste 

container data and provides reports on the Transuranic (TRU) waste sent to WIPP. The 

requirements for the WWIS are discussed in the WIPP Waste Information System Program and 

System Data Management Plan, WP 08-NT.01 (COB-M2009-H2). DOE yearly reports waste 

activity information in the Annual Change Report, Table 3 (DOE/WIPP 08-3317; COB-M2009-

P). 

 WWIS staff demonstrated that the WWIS can receive data and that the WWIS can 

generate needed reports. The inspector obtained copies of the Nuclide Report (COB-M2009- 
Page 8 of 17

W1) and WWIS Waste Container Data Reports (COB-M2009-W2, -W3, and -W4). The 

inspector verified that DOE tracks and annually reports the waste activity at WIPP. 

4.4 Monitoring of Drilling Related Parameters

 DOE committed to measure two drilling related parameters in the CCA: the drilling rate 

and the probability of encountering a Castile brine reservoir. These parameters are measured as 

part of the Delaware Basin Drilling Surveillance Plan, WP 02-PC.02 (COB-M2009-G). This 

surveillance program measures and records many parameters related to drilling activities around 

the WIPP site. The results of the surveillance program are documented annually in the Delaware 

Basin Monitoring Annual Report, DOE/WIPP 08-2308 (COB-M2009-M). 
Page 9 of 17

 
Page 10 of 17

The inspector reviewed the drilling surveillance database, examined drilling rate changes, 

and permitted and active injection wells while interviewing staff. The inspector reviewed Texas 

and New Mexico well database ACCESS files and maps of oil and gas wells around WIPP 

(Figure 2, Oil and Gas Wells Around WIPP, yellow dots are oil wells). The inspector verified 

that DOE tracks and reports the drilling rate and the number of Castile brine encounters near 

WIPP and reports results annually.

4.5 Monitoring of Subsidence Parameters

 DOE committed to measure subsidence at the WIPP site. This parameter is documented 

as part of the WIPP Underground and Surface Surveying Program, WP 09-ES.01 (COB-M2009-

B). DOE performs subsidence surveys at the site annually during pre-closure operations. The 

results of this program are reported annually in the WIPP Subsidence Monument Leveling 

Survey – 2009, DOE/WIPP 09-2293 (COB-M2009-F). 

 Subsidence staff demonstrated the Office Procedure (Section 2 of WP 09-ES4001: COBM2009-N) to the EPA inspector which describes the steps taken to process raw field survey data 

and to calculate final surface elevations published in their annual report (COB-M2009-S62 to -

S64). DOE demonstrated that the subsidence parameter is measured and reported yearly. 

5.0 Summary of findings, observations, concerns, and recommendations.

 Based on program documents, interviews, and field demonstrations during the inspection, 

the Agency concludes that the monitoring program covers the ten monitoring parameters 

required by EPA’s 1998 Certification Decision. This inspection determined that the monitoring, 

sample collection, and sample/data analysis procedures were complete and appropriate; that staff 

were adequately trained and implemented the procedures adequately; and that appropriate quality 

assurance measures are applied. EPA continues to find that DOE has maintained adequate 

parameter monitoring during the past year and has the procedures and requirements in place to 

sustain their program into the next year. EPA has no findings or concerns. 
Page 11 of 17

Attachment A: Inspection Plan and Checklist 

WIPP Monitoring Inspection Plan 

40 CFR 194.42 for the year 2009

Purpose: 

Verify that the Department of Energy (DOE) can demonstrate that the Waste Isolation Pilot Plant 

(WIPP) is monitoring the parameter commitments made in the documentation to support the 

EPA’s certification decision, in particular CCA, Volume 1, Section 7.2, Table 7.7 and Appendix 

MON. This inspection is conducted under the authority of 40 CFR 194, Section 21. 

This inspection is part of EPA’s continued oversight to ensure that WIPP can, in fact, monitor 

the performance of significant parameters of the disposal system. 

Scope: 

Inspection activities will include an examination of monitoring and sampling equipment both on 

and off site, and in the underground. A review of sampling procedures and measurement 

techniques may be conducted. Quality assurance procedures and documentation for each of 

these activities will also be reviewed. 

Focal Areas of This Year’s Inspection: 

- What has changed in the monitoring program this past year? 

- What documentation and procedures have changes? 

- Update the monitoring program and results for the past year. 

- Have any monitoring parameters changed, and have any action limits been achieved? 

Location: This inspection will be held at the WIPP facility location twenty-six miles south east 

of Carlsbad, New Mexico and the surrounding vicinity as needed. 

Duration: The EPA expects to complete its inspection in two days. Each day will begin with an 

opening meeting at 8:00 a.m. and end before 5:00 p.m. with a closeout session. 

Expected Date: Week of July 13, 2009. 

Documents For Review: Just like past years provide latest versions of any documentation 

and/or procedures related to your monitoring program as soon as possible. 
Page 12 of 17

Monitoring Commitments – July 2009 Geomechanical Parameters

# Question Comment (Objective Evidence) 

SAT = Satisfactory

Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Creep Closure; 

b) Extent of Deformation; 

c) Initiation of Brittle Deformation and 

d) Displacement of Deformation Features 

during the pre-closure phase of operations as 

specified in the CCA part of the geomechanical 

monitoring system? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Geotechnical Engineering Program 

Plan, (WP 07-01: COB-M2009-E), 

documents plans to measure, report, and the 

QA requirements related to these activities. 

Section 3.0 of WP 07-01 documents the 

geomechanical monitoring program and 

records the activities associated with this 

program. Section 4.0 of WP 07-01 

documents the quality assurance 

requirements for these activities. 

WIPP site staff discussed changes to the 

program during the past year (COB-M2009-

I8). Staff demonstrated the adequacy of the 

program and that the program produces 

satisfactory results (COB-M2009-S42 to 

S47). They showed samples of remote 

measurements, sample plots, and staff 

preformed underground manual 

measurements of convergence (Photos 2009-

07-15_09 Annual Inspection 00105 to 00110, 

COB-M2009-P1). The inspector toured the 

underground and reviewed the computer 

system and databases used to collect and 

process recorded data. 

Results of this program are documented 

annually in the Geotechnical Analysis Report 

for each reporting period (DOE/WIPP 09-

3177; COB-M2009-A1 and -A2). 

The inspector verified that the geomechanical 

parameters continued to be appropriately 

monitored by DOE. 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1 above? 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

geotechnical investigations are reported 

annually? (CCA, App. MON, Page MON-10) 

WP 07-01, Section 3.2 requires that analysis 

be performed annually and results are 

published in the annual geotechnical analysis 

report (DOE/WIPP 09-3177). 

SAT 
Monitoring Commitments – July 2009 Hydrological Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Culebra Groundwater Composition; 

b) Change in Culebra Groundwater Flow 

Direction 

during the pre-closure phase of operations as 

specified in the CCA part of WIPP’s 

groundwater monitoring plan? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Groundwater Monitoring Program Plan, 

WP 02-1 (COB-M2009-C) documents plans to 

measure, document, report, and the QA 

requirements for these activities. WP 02-1 

records the activities associated with this 

program (Section 4), methods used (Sections 4 

and 5), data analysis (Section 6) and annual 

reporting requirements (Section 7.2.2). 

Section 10.0 of WP 02-1 documents quality 

assurance requirements. 

WIPP site staff discussed changes to the 

program over the past year (COB-M2009-I3). 

Staff explained computer code contouring 

techniques used to develop maps to find flow 

direction in the Culebra and compared results 

to previous the method (COB-M2009-S15). 

SNL staff developed a new procedure called, 

Preparation of Culebra Potentiometer Surface 

Contour Maps, SP 9-9 (COB-M2009-S12) that 

standardizes potentiometer surface 

development. Results are documented 

annually in the WIPP Annual Site 

Environmental Report for 2007 (DOE/WIPP 

08-2225: COB-A2009-C) Figure 6.11, 

Appendix E, and Appendix F. 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1 above? (CCA, App MON, 

Page MON-22) 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

groundwater monitoring program are reported 

annually? (CCA, App. MON, Page MON-22) 

Results are published annually in the WIPP 

Annual Site Environmental Report for 2007 

(DOE/WIPP 08-2225: COB-A2009-C) 

Section 6.0. 

SAT 
Page 14 of 17

Monitoring Commitments – July 2009 Waste Activity Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Waste Activity? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Waste Information System Program and 

Data Management Plan (WP 08-NT.01: COBM2009-H2, Section 6.0) describes how the 

WWIS is used to measure and store waste 

activity information. WWIS User’s manual 

(DOE/CBFO 97-2273: COB-M2009-O) 

documents procedures used to gather, store, 

and process waste activity information. Table 

3 of the Annual Change Report 2007/2008, 

(DOE/WIPP 08-3317: COB-M2009-P) 

updates waste activity information annually. 

WWIS staff discussed changes during the past 

year (COB-M2009-I10) and demonstrated the 

use of the WWIS and generated numerous 

waste related reports (COB-M2009-W2 to 

W4). Such as the Nuclide Report (COBM2009-W1) which summaries isotopes 

emplaced at WIPP. These activities 

demonstrate that waste activity is adequately 

monitored. 

SAT

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1? (CCA, App WAP, page 

C-30) 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

waste activity parameters are reported 

annually? (CCA Volume, Section 7.2.4 

Reporting) 

WP 08-NT.01 Section 6, page 13 “Regulatory 

Reporting” documents that results are reported 

annually and DOE/WIPP 08-3317 verifies that 

results are published annually. 

SAT 
Monitoring Commitments – July 2009 Drilling Related Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Drilling Rate; and 

b) Probability of Encountering a Castile Brine 

Reservoir? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

The Delaware Basin Drilling Surveillance 

Plan, (WP 02-PC.02: COB-M2009-G), 

documents the program to measure, record, 

report, and the QA requirements for these 

activities. Section 7.0 of WP 02-PC.02 

documents quality assurance requirements. 

The Delaware Basin Drilling Database 

Upgrade Process (WP 02-EC3002: COBM2009-I) documents the process used to 

update databases with information from 

various commercial and state sources. 

Drilling rate and Castile brine encounter data 

are reported annually in the Delaware Basin 

Monitoring Annual Report (DOE/WIPP 08-

2308; COB-M2009-M) in Sections 2.5 and 

2.6. 

WIPP site staff discussed changes during the 

past year (COB-M2009-I2). They reported on 

brine encounters, drilling rate calculations, 

and provided maps of drilling activities near 

WIPP (COB-M2009-D2a, D2b). They also 

provide the latest version of the New Mexico 

well databases (COB-M2009-D3). They 

demonstrated that DOE is adequately 

monitoring these parameters through the 

Delaware Basin monitoring program. 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1 above? (CCA, App DMP, 

page DMP-9) 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

drilling related parameters are reported 

annually? (CCA Volume, Section 7.2.4 

Reporting; App DMP, page DMP-9) 

WP 02-PC.02 Section 6.0 documents that 

results are reported annually. DOE/WIPP 08-

2308 verifies that these parameters are 

updated and reported annually. 

SAT 
Page 16 of 17

Monitoring Commitments – July 2009 Subsidence Measurements

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Subsidence measurements? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Underground and Surface Surveying 

Program (WP 09-ES.01: COB-M2009-B), 

documents the program used to measure, 

record, document, report (Section 3.3), and the 

QA requirements (Section 4.0) for these 

activities. Subsidence Survey Data 

Acquisition Report technical procedure (WP 

09-ES4001: COB-M2009-N) documents the 

process for acquiring subsidence data (Section 

1.0), updating the database (Section 2.0), and 

publishing the annual subsidence report 

(Section 2.2). The WIPP Subsidence 

Monument Leveling Survey - 2008 

(DOE/WIPP 09-2293: COB-M2009-F) 

documents that DOE reports this parameter 

annually and the results of this program 

(Section 5.0). 

Site staff discussed changes to the program 

during the past year (COB-M2009-I7). Site 

staff demonstrated that procedures are 

adequately implemented when they showed 

how the raw field survey data collected is 

reduced to useful survey data and how annual 

results are calculated (COB-M2009-S62 to –

S64). They demonstrated that subsidence is 

adequately monitored at the site. 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1? 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

subsidence measurements are reported 

annually? (CCA Volume, Section 7.2.4 

Reporting) 

WP 09-ES.01 Section 3.3.1 documents that 

results are reported annually. DOE/WIPP 09-

2293 demonstrates that results are published 

annually. 

SAT 
Attachment B: Documents Reviewed